While Judge Bernice Donald was still in the process of being vetted by the U.S. Senate for her seat on the Sixth Circuit Court of Appeals back in 2011, the New York Times ran an article declaring the court “the most dysfunctional federal appeals court in the nation.”

The Times lead legal correspondent Adam Liptak wrote at the time that “relations among the judges on the Sixth Circuit have been marred by venomous discord for at least a decade, mostly along ideological lines.”